Samenvatting Colleges International Tax Governance

Samenvatting International Tax Governance
Lecture 1 The taxation of capital income
The right to tax?
 State sovereignty (relation between citizens and the state / solidarity between
citizens)
Reasons to tax
 Revenues
 Income distribution
 Influence behaviour (nudging / pricing of external costs)
Conditions of a good tax system




Taxation of individuals
 Income
 Consumption
 Possession of wealth
 Transfer of wealth
Issues with the taxation of capital




What is income?




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,Timing of the income




Income tax systems
 Comprehensive income tax systems: all income is treated in the same way
 Schedular or dual income tax systems: taxation per category (labor, capital
and business) differs
Causes wealth inequality




Working of income tax systems
Who are taxed?




When is someone resident / citizen for tax purposes?




2

,Tie-breaker rule (article 4 OECD-model tax treaty)




Home




Centre of vital interest




Habitual mode




3

, International allocation of taxing rights
Allocation of taxing rights




Allocation of taxing rights: capital income




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